- 15 -
provide those documents at that time because they could not
identify which of the materials they brought to trial Poole had
seen. Thus, the Court told petitioners that it would admit into
evidence documents that Poole had seen if petitioners served
copies of them on the Court and respondent's counsel within 30
days after the trial.2
II. OPINION
Respondent's determinations in the notices of deficiency are
presumed to be correct, and petitioners bear the burden of
proving otherwise. Rule 142(a); Welch v. Helvering, 290 U.S.
111, 115 (1933).
A. Petitioners' Constitutional and Other Contentions
Petitioners contend that respondent's agents have been
abusive to petitioners and that respondent has violated several
of petitioners' rights under the U.S. Constitution and Civil
Rights Acts of 1963 and 1964.
1. Events Before and During The Audit
Petitioners contend that respondent's agents were abusive to
them before and during the audit of these cases. Petitioners
contend that respondent's agents had a personal vendetta against
them. Mr. Owens testified that he had a confrontation with an
2 Respondent did not object to the admission of these
documents under this procedure.
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